United States Environmental Protection Agency
SEPA
Fugitive Dust Control at TSCA
PCB Cleanup Sites
November 2024
EPA 530-R-24-005
Disclaimer
This document is intended to be used as an informal reference, and as such, is not a
complete statement of all applicable polychlorinated biphenyls (PCB) requirements.
This document does not replace or supplant the requirements of the Toxic Substances
Control Act (TSCA) PCB regulations. Please refer to the PCB regulations at 40 C.F.R.
Part 761 for specific regulatory requirements. In case of conflict between this document
or portion(s) thereof and any PCB regulatory requirement, the TSCA PCB regulations
supersede this document. Also, as indicated by the use of non-mandatory language such
as "may," "should," and "can," these materials identify a suite of practices and provide
suggestions and do not create any new legal obligations or limit or expand obligations
under any federal, state, tribal, or local law.
Disclaimer
This document was developed with support from the U.S. Army Corps of Engineers (as
part of/under the umbrella of) EPA Region 9 Interagency Agreement DW096959406.
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Executive Summary
The TSCA PCB regulatory program is not delegable to states and the management and
enforcement of the program is currently under the exclusive authority of the EPA. This Fugitive
Dust Control at TSCA PCB Cleanup Sites manual was developed as a resource to provide a suite
of practices for PCB cleanup actions that, if implemented, will help ensure PCBs in fugitive dust
releases to ambient air present no unreasonable risk of injury to health or the environment. The
manual's content is modeled after local fugitive dust rules adopted in certain areas of California,
Nevada, and Arizona that require stringent dust control measures (DCMs). While activities
capable of generating fugitive dust at PCB cleanup sites are similar across the country,
approaches to effectively control fugitive dust may vary in different areas depending on a
number of factors, e.g., climate, soil. This should be taken into account when applying the
manual's content to PCB cleanup sites in various locations.
Remedial and other activities at cleanup sites have the potential to generate dust, and
uncontrolled PCB-contaminated fugitive dust releases to ambient air potentially result in
unacceptable risks to human health. The increased health risk is a consequence of the combined,
or co-exposure to various fractions of particulate matter, and the hazard of PCBs. As a result,
effective fugitive dust prevention, monitoring, and control practices are necessary to protect
human health. Ecological protection may also require dust control provisions.
This document contains DCMs and air monitoring protocols, including an approach that uses a
health-based air monitoring trigger (i.e., action) level to guide implementation of dust-generating
activities and DCMs during the cleanup, in order to ensure protection of public health. It also
specifies time-critical response actions to address acute or gross fugitive releases or conditions
that could increase the likelihood of such releases. The Appendix A language can be tailored to
site-specific activities. Appendix B is a checklist that can be used to comprehensively identify
any dust-generating activities that could occur at a particular PCB cleanup site. It can also be
used to indicate whether there are sensitive uses on or adjacent to the site, such as a school or
daycare center, that warrant extra dust control precautions.
This document is a resource on dust controls for TSCA Project Managers (PMs) reviewing
cleanup plans and working with Responsible Parties (RPs) managing PCB-contaminated sites or
media subject to PCB regulations under 40 CFR 761.61. It is intended to: (1) Facilitate EPA
approvals that are sufficiently comprehensive regarding site-specific dust controls to consistently
protect public health and the environment during cleanup of sites pursuant to 40 CFR 761.61; (2)
Inform PMs on what may be needed for effective dust controls at PCB cleanup sites for various
dust-generating activities; (3) Increase efficiency of communications between PMs and RPs; and
(4) Streamline EPA's review when dust control best practices are included by RPs in TSCA
submittals.
RPs may choose to not use the appendix tools, as this document does not create, limit, or expand
obligations under any federal, state, tribal, or local law. If EPA determines that particular dust
controls are required for a site and that the dust controls submitted to EPA are inadequately
protective, EPA's approval can contain site-specific approval conditions related to dust controls,
including the examples provided in Appendix A. EPA retains all authority to modify proposed or
approved dust controls if needed to prevent unreasonable risk to public health or the
environment.
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Table of Contents
1. INTRODUCTION & DISCUSSION 5
1.1 Purpose 5
1.2 Applicability 5
1.3 Human Health Framework 6
1.4 Regulatory Overview 7
Toxic Substances Control Act 7
Clean Air Act 8
Local Dust Control Rules 8
Fugitive Dust and Particulate Matter 9
2. DUST CONTROL PLANS 9
2.1 Dust Control Plan Elements in TSCA Submittals 9
3. DUST CONTROL MEASURES 11
3.1 Dust Control Measures as a Component of Dust Control Plans 11
3.2 Potential Dust-Generating Activities 12
3.3 Investigation-Derived Waste 13
3.4 Sensitive Uses 13
4. AIR MONITORING 14
4.1 Air Monitoring as a Component of Dust Control Plans 14
4.2 Air Monitoring Trigger Level 15
4.3 Exceedances of Trigger Level 16
5. OTHER DUST CONTROL PLAN COMPONENTS 17
5.1 Dust Control Supervisor 17
5.2 Site Signage 17
5.3 Recordkeeping 17
5.4 Compliance and Reporting 18
6. REFERENCES 18
APPENDICES
Appendix A: Dust Control Example Language
Appendix B: Dust-Generating Activity & Sensitive Use Example Checklist
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Acronyms
CAA - Clean Air Act
CFR - Code of Federal Regulations
DAS - Data Acquisition System
DCMs - Dust Control Measures
DCPs - Dust Control Plans
EPA - United States Environmental Protection Agency
HEPA - High Efficiency Particulate Air
IDW - Investigation-Derived Waste
LCRD - Land, Chemicals, and Redevelopment Division
|ig/m3 - Microgram per Cubic Meter
MPH - Miles Per Hour
NAAQS - National Ambient Air Quality Standards
PCBs - Polychlorinated Biphenyls
PMs - Project Managers
PMio - Particulate Matter <10 microns
ppm - Parts Per Million
RfD - Reference Dose
RPs - Responsible Parties
SCAQMD - California's South Coast Air Quality Management District
SIP - State Implementation Plan
SWPPP - Storm Water Pollution Prevention Plan
TSCA - Toxic Substances Control Act
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1. INTRODUCTION & DISCUSSION
1.1 Purpose
This document discusses the need for dust controls and provides example language for DCMs to
prevent or minimize fugitive releases that could potentially contain PCBs, paired with ambient
monitoring of PMio and oversight methods to verify the effectiveness of DCM implementation.
It is designed to help RPs develop and implement content for Dust Control Plans (DCPs) for
PCB cleanup sites subject to TSCA and to help EPA PMs evaluate this content in TSCA
submittals. Specifically, it informs dust control content for inclusion in 40 CFR part 761.61(a)
Notifications and 40 CFR 761.61(c) Applications. EPA PMs may use the Appendix A language
to prepare comments on TSCA submittals or incorporate it into conditions of approval for
Applications that do not contain adequate measures to control dust, in order to assure no
unreasonable risk of injury to health or the environment. Once approved by EPA, the
commitments to implement DCMs contained in a TSCA Application or Notification pursuant to
40 CFR 761.61 are enforceable by EPA.
A compilation of example DCMs is provided in Appendix A as a tool for RPs to use in their
development of DCPs and for PMs in their evaluation of the adequacy of DCPs proposed for
PCB cleanup sites. The DCMs discussed herein would not supersede federal, state, or local
regulations for the prevention and minimization of fugitive dust.1 However, implementing the
DCMs in Appendix A may involve additional or more stringent dust control practices relative to
those contained in local fugitive dust regulations, particularly those that apply in areas that have
historically attained the federal PMio standard.
1.2 Applicability
This document is designed to address any dust-generating activities that could disturb PCBs that
are known to or may be contained in soils, sediments, aggregate, or pavement located at sites
subject to 40 CFR 761.61. DCMs for removal and renovation of building materials containing
PCBs described on the following EPA webpages should be utilized:
Steps to Saf item ent Activities
Steps to Safe Renovation and Repair Activities
The DCMs in this document are categorized according to activities that could generate fugitive
dust, a subset of which are relevant to any given PCB cleanup site. Thus, when developing
content to include in a DCP, first determine which of the listed dust-generating activities in
Section 3.2 are applicable to a particular PCB cleanup site, then utilize the language in Appendix
A to identify DCMs associated with these activities.
1 See 40 CFR 761.50(a)(6) stating that any person storing or disposing of PCBs is also responsible for determining
and complying with all other applicable Federal, State, and local laws and regulations. Also, the DCMs must be
selected and implemented in a manner that complies with all applicable TSCA PCB requirements for storage of PCB
waste, including that any person who holds PCB waste must store it in accordance with § 761.65. See 40 CFR
761.50(c).
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The Appendix A language does not address stormwater pollution prevention controls. Applying
water to control fugitive dust can have implications on stormwater runoff pollution prevention. It
is advisable for RPs to utilize water hoses with nozzles that permit the use of a fine, low-pressure
spray or mist such that water doesn't pool and/or run off from the remedial worksite area. Most
sites involving excavating, grading, or clearing activities must adopt a State-or EPA-approved
Storm Water Pollution Prevention Plan (SWPPP)2 to prevent sediment-containing runoff from
entering surface water or storm drains.
TSCA requirements for decontamination of surfaces3 that come into contact with PCB
remediation waste can be found in 40 CFR 761.79. Decontamination activities can closely
interconnect with DCMs designed to prevent off-site track-out of fugitive dust from haul trucks
or equipment used at a cleanup site. Appendix A DCMs for Track-out Prevention and Control
include footnotes mentioning decontamination considerations for cleaning soil from tires and
undercarriages. However, this document does not otherwise address TSCA decontamination
requirements, and RPs should ensure compliance with 40 CFR 761.79 for decontamination of
surfaces with PCB contamination.
1.3 Human Health Framework
United States Environmental Protection Agency's (EPA's) regulatory authority under the Toxic
Substances Control Act (TSCA) is critical for the protection of human health and the
environment. Human exposure to dust-generating activities at sites contaminated with hazardous
constituents can pose an increased risk to public health. Because uncontrolled releases of fugitive
dust entrained with toxic constituents potentially represent an unacceptable risk to human health
and the environment, the effective prevention and mitigation of fugitive dust is critical during
TSCA regulated activities. The increased health risk is primarily a consequence of the combined
inhalation hazard of dust - as measured by various fractions of particulate matter - and the
toxicity of the polychlorinated biphenyls (PCBs).
Chronic human exposure to particulate matter results in a wide range of adverse human health
impacts. Both EPA and state agencies, such as California EPA (CalEPA), have characterized the
relationships between the myriad of cardiovascular and respiratory adverse health effects of, and
the magnitude of human exposure to various particulate matter fractions. Those relationships
underline the fundamental scientific basis by which federal and state ambient air quality
standards for particulate matter have been established.
The concentration of the California ambient air quality standard for the < 10 micron fraction of
particulate matter is 50 micrograms per cubic meter (|ig/m3), and various air quality authorities
apply this concentration as an action or trigger level to control routine nuisance and fugitive dust
releases. The concentration of the National Ambient Air Quality Standards (NAAQS) for the <
10 micron fraction of particulate matter is 150 |ig/m3 per 40 CFR part 50. Neither health-based
2 An EPA-approved SWPPP is only needed in areas where the State or Tribal agency is not authorized to implement
EPA's National Pollutant Discharge Elimination System. EPA guidance on developing a SWPPP can be accessed on
EPA's website: https://www.epa.gov/npdes/developing-stormwater-poHntion-prevention-plan-swppp.
3 E.g., truck beds, tires, and undercarriages, earth-moving equipment buckets, tires, and undercarriages, etc.
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standard was derived, nor is considerate of, the additional health hazard posed by particulate
matter co-contaminated with PCBs.
PCBs represent a large and diverse family of synthetic organic compounds that are probable
carcinogens and have been demonstrated to cause a variety of adverse, systemic health impacts.
The health hazards of the more highly chlorinated members of the PCB family - when identified
as discrete Aroclor fractions - have been well characterized by EPA. The Agency has established
quantitative estimates which characterize the carcinogenic potency, and the non-cancer hazards
posed by exposure to PCBs. The PCB Reference Dose (RfD) represents the amount of daily PCB
exposure that is acceptable over a lifetime. However, like air quality standards for particulate
matter, EPA's PCB RfD was not derived, nor is considerate of the additional health risk
conferred by concurrent exposures with particulate matter.
Because PCBs have a wide-range of volatility (semi-volatile organic compounds [SVOCs]), they
have been identified in both vapor (gaseous) and particulate-bound fractions in ambient air.
Vapor-phase (gaseous) fractions tend to include the lower molecular weight or lower-chlorinated
members of the PCB family, while the more highly chlorinated and high molecular-weight
members of the PCB family enjoy increased adsorption affinity with particulate matter.
Direct inhalation of various fractions of particulate matter, combined with both vapor and
particle-bound fractions of PCBs, represents the dominant route of human exposure during
typical dust-generating activities at TSCA sites. Because airborne PCBs cannot currently be
measured by real-time, direct-reading instrumentation, the fraction of fugitive dust that
constitutes particulate matter <10 microns in size (PMio) can be used as an effective proxy or
surrogate for estimating the concentration of respirable particulate matter containing PCBs.
Because the PMio fraction of fugitive dust is not visible to the naked eye, the ability to observe a
visible dust release with PCB constituents approaching property boundaries is highly uncertain.
Buoyant fugitive releases tend to become less visible with increasing ambient dilution and, under
some conditions, a downwind stationary PMio monitor at a property boundary may not capture
actual PMio emissions escaping the site boundary. The objective of fugitive dust controls and
associated monitoring at PCB cleanup sites is to ensure that PCB-entrained dust does not leave
site boundaries. This warrants a multi-faceted, dynamic approach to address dust-generating
activities, including: (1) implementing prescribed DCMs designed to proactively prevent the
initial generation of fugitive dust releases; (2) high wind and visible plume restrictions; and
(3) ambient PMio monitoring at the property boundary, or alternatively, at the remedial worksite
perimeter, along with protective response actions.
1.4 Regulatory Overview
Toxic Substances Control Act
Enacted in 1976, TSCA gives EPA authority over chemical substances and mixtures. This statute
specifically addresses lead-based paint, asbestos, and PCBs. The PCB regulations, 40 CFR part
761, were promulgated to implement TSCA requirements regarding the production, use, and
disposal of PCBs. Within these TSCA PCB regulations, 40 CFR 761.61 contains provisions for
the cleanup and disposal of PCB remediation waste. 40 CFR 761.61(a), "Self-implementing on-
site cleanup and disposal of PCBs," (Notification), 40 CFR 761.61(b), "Performance-based
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disposal," and 40 CFR 761.61(c), "Risk-based disposal approval," (Application) are options for
cleanup of PCB remediation wastes. PCB remediation waste is defined in 40 CFR 761.3.
Examples of PCB remediation waste can also be found in EPA 's PCB Facility Approval
Streamlining Toolbox, May 2017.
For purposes of this document, "TSCA submittal" refers to Notifications submitted to EPA
pursuant to 40 CFR 761.61(a) or Applications submitted to EPA pursuant to 40 CFR 761.61(c).
Both Notifications and Applications are subject to EPA review, which may include EPA
requesting more information. EPA final action may include issuance of an approval, disapproval,
or conditional approval.4
Clean Air Act
The Clean Air Act, as amended, 42 USC § 7401 et seq. (CAA) is the comprehensive federal law
regulating air emissions. Among other things,5 the law authorizes EPA to establish NAAQS for
six common air pollutants, including particulate matter, and to regulate emissions of air
pollutants considered harmful to public health and the environment. States are required to
develop state implementation plans (SIPs) to meet and maintain the NAAQS. With the
implementation of SIPs, states were required to designate air quality control regions within the
state. EPA must designate areas as meeting (attainment) or not meeting (nonattainment) for each
N AAQS. SIPs contain air pollution measures, but due to differences in the air quality and mix of
air pollution sources among regions, the measures may vary largely between states and within a
state between air quality control regions. In some areas, e.g., the South Coast Air Basin
(California), Clark County (Nevada), and the Phoenix metropolitan area (Arizona), SIPs include
fugitive dust rules adopted by local air quality management agencies as a key component of a
regional strategy to attain or maintain one or more of the NAAQS that address particulate matter.
Local Dust Control Rules
Local rules and/or permit requirements governing fugitive dust generated at soil-disturbing,
construction, and demolition projects may apply in the area where a PCB cleanup site is located.
Local dust rule and permit requirements must be followed when conducting dust-generating
activities, as enforced by local regulatory agencies. Compliance with a local fugitive dust rule
that applies outside of a federal PMio nonattainment or maintenance area and that is not designed
to address toxic contaminants such as PCBs may be insufficient to control dust from PCB
cleanup sites regulated under TSCA. Local dust rules adopted for inclusion in SIPs that address
the federal PMio standard generally establish more stringent requirements than most, e.g., in
terms of coverage, clarity, replicable standards and test methods, recordkeeping, dust control
oversight, and enforceability. Furthermore, one local fugitive dust rule in California specifically
4 See 40 CFR 761.6l(a)(3)(ii) and 40 CFR 761.61(c)(1). Subsection 761.61 (a)(3)(ii) contains information
concerning regulatory timeframes for EPA's approval, disapproval, or request for additional information on
Notifications.
5 The CAA has specific requirements for hazardous air pollutants, which include PCBs. See Section 112(b)(1) of the
CAA, 42 USC § 7412(b)(1). This document does not provide guidance on the CAA.
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addresses toxic contaminants, including PCBs, in soils: SCAQMD Rule 1466, "Control of
Particulate Emissions from Soils with Toxic Air Contaminants,6
Fugitive Dust and Particulate Matter
Fugitive dust is a form of particulate matter or other fine materials that have become airborne by
wind or mechanical disturbance. This dust can be composed of toxic substances such as asbestos,
heavy metals, pesticides, PCBs, and/or other harmful contaminants. The degree to which dust or
material becomes "fugitive" depends on many factors such as soil/material characteristics,
soil/material moisture content, current/past site activities, and current weather conditions.
Fugitive dust emissions generated from soil-disturbing activities at any given site are dependent
on the site activities, exposed surface area, wind exposure, moisture content of the materials on-
site, and other characteristics of the material on-site.
The regulation and mitigation of fugitive dust as a source of particulate matter pollution is based
upon scientific findings that dust particles are easily inhaled and smaller particle fractions (e.g.,
<10 microns in size) are deposited and impact critical junctures of the pulmonary system.
Numerous scientific studies have linked particulate matter exposure to multiple adverse health
impacts, including premature death in subgroups with heart or lung disease, nonfatal heart
attacks, aggravated asthma, and increased respiratory distress syndrome.7 Fugitive dust releases
entrained with toxic constituents elicit an increased health risk because of the multiple hazards
that are specific to each contaminant or family of contaminants. Fugitive dust fractions laden
with a toxic contaminant(s) that mobilize off-site can potentially pose a health threat to human
and the environment whether airborne or upon deposition.
2. DUST CONTROL PLANS
2.1 Dust Control Plan Elements in TSCA Submittals
EPA strongly recommends that cleanup plans submitted to EPA pursuant to TSCA contain a
description of dust prevention and suppression methods that will be used to control fugitive
releases associated with cleanup of PCB remediation waste without generating unreasonable
amounts of runoff, and a description of real-time ambient air fugitive dust monitoring activities -
including applicable site-specific dust action levels.8 PMio can be used as an effective proxy or
surrogate for estimating the concentration of respirable particulate matter containing PCBs.
The PCB regulations in 40 CFR 761.61(c) require that a determination of no unreasonable risk of
injury to health or the environment be made by EPA in connection to its risk-based cleanup
approvals. Failure to include detailed and comprehensive dust control provisions in a PCB
cleanup plan may result in EPA incorporating specific dust control provisions as a condition of
approval of a submitted 40 CFR 761.61(c) Application. The contents of TSCA submittals
approved by EPA are legally binding, including specific actions proposed by the RP to prevent
6 SIPs do not typically include rules that address hazardous air pollutants in fugitive dust.
7 https://www.epa.gov/pm-poHntion/health-and-environmental-effects-particniate-matter-pm.
8 EPA PCB Facility Approval Streamlining Toolbox, May 2017.
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fugitive dust releases, as well as any conditions in 40 CFR 761.61(c) approvals. Such conditions
may require the RP to implement a specific set of fugitive dust control measures and protocols
for PMio monitoring, should adequate measures not be included in the submitted TSCA
Application.
A comprehensive DCP should include content addressing the following elements:
1. General Project Information that will be included in the DCP
2. A Detailed Description of DCMs that will be Implemented for Each Dust-Generating
Activity
3. Air Monitoring Protocols and Trigger Level(s)
4. Methods that will be Employed to Ensure DCMs and Air Monitoring Protocols Are
Effectively Implemented:
a. On-Site Dust Control Supervisor (including specific authorities and
responsibilities to direct the actions of on-site personnel involved in both dust-
generating activities and dust control activities)
b. On-Site Signage
c. Recordkeeping
d. Compliance and Reporting
Appendix A contains example language for the above listed elements of comprehensive DCPs.
RPs may choose to not use the appendix tools as this document does not create, limit, or expand
obligations under any federal, state, tribal, or local law. It is an informational manual only; site-
specific considerations may warrant additional or alternative dust control provisions. This
example language is designed so that PMs can share and discuss it with RPs during early
engagement when the RP is developing a PCB cleanup site workplan for submittal to EPA in a
TSCA Notification or Application. This same language can be utilized by EPA PMs to evaluate
the dust controls identified in a TSCA Notification or Application, to insert into correspondence
regarding a submitted TSCA Notification or Application, or to develop site-specific approval
conditions in a 40 CFR 761.61(a) self-implementing disposal approval letter or a 40 CFR
761.61(c) risk-based disposal approval for a PCB cleanup site.
The Appendix A language reflects DCMs contained in EPA-approved rules adopted in current or
former PMio nonattainment areas in EPA Region 9, as well as SCAQMD Rule 1466 "Control of
Particulate Emissions from Soils with Toxic Air Contaminants. " RPs may use Appendix A, but it
may be necessary for language to be more stringent in order to be protective in some situations,
particularly in areas with little propensity for fugitive dust generation. DCPs that fully
incorporate the Appendix A content (customized to reflect site-specific dust-generating activities
and air monitoring trigger levels) should be more than adequate to comply with most local dust
control rule requirements.9
9 For PCB cleanup sites located within the jurisdiction of the South Coast AQMD, Rule 1466 requirements may
apply depending on the applicability criteria in Rule 1466. There are a few differences in Appendix A language with
respect to PMio air quality monitoring and trigger levels relative to Rule 1466. Also, there may be additional
requirements in Rule 1466 not incorporated into the Appendix A language. However, the PMio trigger level in
Appendix A may be more stringent than Rule 1466, depending on site-specific PCB levels. Implementing the
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While the substantive content of all dust control provisions (e.g., measures, methods, protocols,
action levels, and planned locations10 of monitors and wind screens) proposed by the RP should
be provided in the TSCA submittal to EPA, the DCP itself can be completed following EPA's
approval of the Notification or Application.11 Ultimately, RPs typically create the DCP as a
separate document containing general project information, DCMs, air monitoring protocols, site
signage, and oversight methods for distribution to personnel implementing the cleanup.
Sections 3, 4, and 5 of this document describe the content contained in Appendix A and provide
instructions for how to customize the Appendix A language to reflect site-specific conditions
where appropriate.
3. DUST CONTROL MEASURES
3.1 Dust Control Measures as a Component of Dust Control Plans
DCMs are one component of DCPs to be included in TSCA submittals to EPA. To facilitate
more consistent review of DCMs by PMs, and discussion of possible DCMs with RPs to ensure
that appropriate site-specific DCMs are identified and implemented to prevent the generation of
fugitive dust at PCB cleanup sites, Appendix A of this document provides example language for
standardized DCMs for a variety of dust-generating activities, along with standardized
definitions of terms used in the DCM descriptions.
The language presented in Appendix A for DCMs and definitions of terms used in DCM
descriptions together provide for a high degree of dust control upon proper implementation. The
definitions, in combination with the DCMs. provide clarity both for applicability and for
confirming the effectiveness of the dust controls implemented. When utilizing the Appendix A
language, the definitions can either be incorporated separately as presented in Appendix A or
integrated into the language of the DCMs. DCM language pulled from other sources, such as
local dust rules that apply in areas that have always attained the federal PMio standard, may
appear similar but not provide for as effective dust control relative to the Appendix A definitions
and DCM language.
The definition of "Stabilized Surface" reflects language drawn from SCAQMD Rule 1466,
which references test methods contained in other SCAQMD rules to demonstrate a stabilized
surface. Two of these test methods are provided in Attachment 1 of Appendix A, with minor text
additions/clarifications. Because both the definition of a stabilized surface and the relevant test
Appendix A DCMs would not be expected to pose any conflicts with meeting Rule 1466 requirements. See also
footnote 5, above.
10 For example, a map can be provided showing the general locations at which the upwind and downwind PMio
monitors, weather station or on-site meteorology monitor, and wind screens will be placed in relation to the remedial
worksite area(s) with PCB-containing media.
11 Note that the specific dust control provisions contained in an EPA-approved 40 CFR 761.61(a) Notification or 40
CFR 761.61(c) Application must be implemented at the site, along with any related conditions in EPA's approval,
and thus the RP incorporates all these provisions into the DCP in order to facilitate and demonstrate compliance
with EPA's approval.
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methods are, together, important components of DCMs designed to create and maintain a
stabilized surface, they should be included (or specifically referenced) in the description of such
DCMs and incorporated into DCPs as needed.
While the DCM language in Appendix A is standardized for use across PCB cleanup sites, which
DCMs are incorporated into a TSCA submittal and subsequent DCP depends upon the dust-
generating activities to be carried out at the PCB cleanup site. DCMs for dust-generating
activities that are not relevant to a particular cleanup site can be deleted when referencing or
using Appendix A (see Section 3.2 for a list of potential dust-generating activities by category).
Other aspects of the Appendix A example language intended to be customized are indicated with
italicized text.
Site-specific circumstances not referenced here may also warrant use of modified DCM
language. For example, Appendix A includes a DCM providing for the remedial worksite area to
be surrounded by 6-foot-tall fencing that meets specific parameters; however, if one side of a
remedial worksite area is bounded by a solid wall at least 6 feet high, the DCM may propose to
utilize the solid wall as a wind break in lieu of fencing on the applicable side of the remedial
worksite area.
3.2 Potential Dust-Generating Activities
The following is a list of dust-generating activities for which standardized DCMs and associated
definitions are provided in this document. The list of dust-generating activities addressed in
Appendix A encompass activities that commonly occur at PCB cleanup sites:
1. Sitewide12
2. Excavating, Trenching, and Other Earth-Moving Activities
3. Stockpiling
4. Truck Loading, Unloading, and Transport
5. Track-out Prevention and Control
6. Disturbed Surface Areas
7. Unpaved Roads, Haul Routes, and Parking Areas
8. Pavement Removal
9. Paving/Sub grade Preparation
10. Clearing or Cleaning Foundations and Slabs
11. Storm Drain Sediment Cleanup
12. Investigation-Derived Waste
13. Other Dust-Generating Activities and Dust Control Measures13
Both Appendix A and Appendix B of this document are designed to inform a comprehensive
approach to assessing activities at a PCB cleanup site that have the potential to generate fugitive
dust. Appendix A includes DCMs for the potential dust-generating activities listed in this
12 This category includes dust control measures that apply sitewide to various earth-moving activities (versus a
single type of dust-generating activity) and to miscellaneous sources.
13 This category can be utilized by PMs or RPs to insert other site-specific miscellaneous dust-generating activities
or DCMs.
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section14 and may be tailored to remove DCMs for activities that are not applicable/relevant to a
particular PCB cleanup site. Appendix B "Dust-Generating Activity & Sensitive Use Example
Checklist" can be used to identify dust-generating activities and sensitive uses that are applicable
to a specific PCB cleanup site.
3.3 Investigation-Derived Waste
Investigation-Derived Waste (IDW) can be generated from soil sampling (e.g., drill cuttings) and
from installing groundwater monitoring wells (soil removed to make space for the wells).
Groundwater well installation can result in two to three 55-gallon drums of IDW per well
installed. IDW can be generated during site characterization activities prior to submittal of a
TSCA notification or application to EPA or it can be generated in tandem with an approved
cleanup action or as a post-cleanup action. Appendix A contains standardized DCMs for IDW
that can be applied, as needed, in the pre-approval, approval, and/or post-approval project phase.
The PCB regulations require soil to be characterized for disposal based upon in situ PCB
concentrations. If PCB levels in soil are unknown/uncharacterized at the time IDW is generated,
the IDW should be managed so as to prevent generation of fugitive dust, not comingled with
IDW from other sampling locations, and placed in a sealed container(s) until laboratory results
for PCBs become available.
If a significant amount of IDW is anticipated to be generated, e.g., enough to fill more than one
55-gallon drum, the EPA PM should ensure the sampling workplan or monitoring well
installation workplan submitted to EPA for approval or concurrence contains specific dust
control measures addressing the IDW to be generated. This is particularly important when the
IDW will be generated from areas known to contain PCB-impacted soil.
3.4 Sensitive Uses
Appendix A includes a few additional DCMs for PCB cleanup sites on which an anthropological
sensitive use15 is located or adjoining to the site. The purpose is to provide extra dust control
precautions to protect sensitive receptors, such as children and the elderly, in close proximity to
the cleanup site.
The DCMs for sensitive uses in Appendix A are drawn from Section (e)(15) of SCAQMD Rule
1466 which apply to schools, joint use agreement properties, and adjacent athletic areas.
However, the Appendix A language expands applicability of the DCMs from Rule 1466 Sections
(e)(15)(C) and (e)(15)(D) to daycare centers and senior care centers. Definitions associated with
sensitive uses can be found in Appendix A "Dust Control Measures Definitions."
The Appendix B example checklist includes sensitive uses that account for ecological receptors,
e.g., aquatic species. Appendix A does not include specific DCMs to address ecological
receptors that may be impacted by deposition of PCB-impacted particulate matter released in
14 As noted in Section 1.4 "Applicability", Appendix A does not include DCMs for building materials that contain
PCBs.
15 A facility (indoor or exterior area) occupied by sub-populations that may be particularly vulnerable to airborne
particulates.
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fugitive dust plumes. However, PCB cleanup sites located on or in close proximity to
ecologically sensitive uses may warrant full implementation of DCMs and PMio monitoring
provisions in this manual to prevent fugitive dust generation.
4. AIR MONITORING
4.1 Air Monitoring as a Component of Dust Control Plans
Air monitoring protocols represent a critical component of site-specific DCPs, and their
description should be included in TSCA submittals. Appendix A provides standardized language
for air monitoring protocols that can be generally applied across a wide range of PCB sites. In
limited circumstances, EPA PMs may determine that air monitoring is unnecessary in
consideration of several site-specific factors, such as small site or remedial worksite dimensions,
small quantity of soil to be disturbed, low maximum PCB concentration identified, and whether
special equipment with high effectiveness for fugitive dust control will be utilized. In such cases,
other components of DCPs should still be implemented, including DCMs and visual observations
to check for the presence of dust plumes.
This manual recommends an approach that incorporates a default PMio trigger level of 25 |ig/m3
because of the increased human health hazard posed by inhalation of both PCBs and particulate
matter fractions. Furthermore, when PCB media concentrations equal or exceed 1,200 parts per
million (ppm), Appendix A contains a methodology for deriving a more protective and site-
specific trigger level which incorporates EPA's PCB RfD. The RfD represents the amount of
total daily PCB exposure that is acceptable, and the recommended approach for derivation of
concentration-dependent trigger levels is provided in Section 4.2 of this document.
The monitoring section of Appendix A (Section III) contains italicized text indicating where
customization of text is needed, for example, to reflect the appropriate PMio trigger level for the
site, as derived consistent with Section 4.2 below.
Appendix A specifies that the PMio monitors will be placed as close to the property line as
feasible, or alternatively, at the remedial worksite perimeter. Thus, flexibility is provided to RPs
that opt to place the PMio monitors at the remedial worksite perimeter. At larger sites, placing
the monitors at the remedial worksite perimeter may better enable the RP to document PMio
concentrations associated with worksite operations versus other potential sources of PMio
concentrations. Appendix A provides for a minimum of one PMio monitor upwind and one
monitor downwind of the area(s) of on-site Earth-Moving Activity or Dust-Generating Activity.
Proposed placement of PMio monitors - whether at the remedial worksite perimeter or property
boundary - and the number of monitors to gauge PMio concentrations should be informed by
site-specific circumstances and supported by an adequate rationale.
Appendix A specifies that the PMio monitors will be operated with the heated sampler inlet on.
This is to ensure that humidity does not affect the PMio results, and all instruments are operating
in a consistent manner while producing results that are as accurate as possible.
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4.2 Air Monitoring Trigger Level
Uncontrolled dust releases to ambient air from PCB contaminated media can pose an increased
hazard to human health. The combined, or co-exposure, to both dust - as measured by particulate
matter - and PCBs in fugitive releases increases the likelihood of unacceptable risks to human
health. Because the PCBs encompass a broad range of synthetic constituents with a wide range
of volatility (Semi-Volatile Organic Compounds), they have been identified in both vapor
(gaseous) and particulate-bound fractions in ambient air. Ambient air vapor-phase (gaseous)
fractions tend to include the lower molecular weight or lower-chlorinated members of the PCB
family, while the more highly chlorinated and high molecular-weight members of the PCB
family enjoy increased absorption affinity given the substantial surface area of particulate matter.
Current health-based standards are not considerate of the additional human health hazard posed
by particulate matter containing PCBs (e.g., California Ambient Air Quality Standard for the 10
micron fraction of particulate matter is 50 |ig/m3. The NAAQS for the 10 micron fraction of
particulate matter is 150 |ig/m3). In addition, airborne PCBs cannot currently be measured by
real-time, direct reading instrumentation, therefore the fraction of fugitive dust that constitutes
PMio can be used as an effective proxy or surrogate for estimating the concentration of respirable
particulate matter containing PCBs. Because of the additional health risk from the combined, or
co-exposures, between particulate matter and PCBs, this manual recommends an approach that
incorporates a default trigger level for PMio of 25 |ig/m3 as protective when maximum PCB
media concentrations are less than 1,200 ppm.
EPA PMs consider site-specific factors in determining air monitoring protocols that are
sufficiently protective. EPA Regions may also account for regional and site-specific factors to
assess whether an alternative trigger level is sufficiently protective. The default trigger level (25
|ig/m3) is protective when maximum PCB media concentrations are less than 1,200 ppm. To
remain protective of public health when maximum PCB media concentrations equal or exceed
this threshold, RPs may derive a site-specific trigger level (Cda) which incorporates EPA's RfD
for PCBs. The PCB RfD should be specifically modified to accommodate a child receptor as this
derivation results in dust trigger levels that are more protective of a wide range of sensitive
subgroups. Refer to Figure 1 for graphical representation utilizing the following approach:
Step 1: Derive the PCB Reference Concentration suitable for a "default" child:
RfC = RfDo x BW/ IR
Step 2: Determine PCB Site-specific trigger level for PMio in air using:
Cda = RfC x (1.0E+09) / Cca
Cda = Maximum allowable concentration of PMio in air (|ig/m3)
RfC = Inhalation reference concentration (mg/m3)
Cca = Maximum PCB concentration in soils, sediments, or other disturbed material (e.g.,
concrete) (mg/kg)
1.0E+09 = Unit conversion factor (|ig/kg)
RfDo = Oral reference dose (2E-5 mg/kg-day)
BW = Body weight (15kg)
15
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IR = Inhalation rate (10m3/day)
Figure 1. Determination of the Maximum Allowable Concentration of PM10 in Air
Maximum Allowable Concentration ofPM10 in Air (ug-'m ')
4.3 Exceedances of Trigger Level
Appendix A provides standard language for addressing an exceedance of the ambient air
monitoring trigger level for a 120-minute rolling average period. The PMio concentration is
calculated by subtracting the results of the upwind monitor(s) from the downwind monitor(s) for
the same averaging period. If the trigger level is exceeded, all dust-generating activities are to
cease, and additional DCMs are to be implemented. Once PMio concentrations are less than the
applicable trigger level averaged over 30 minutes, site activities can resume. SCAQMD's Rule
1466 is the source reference for both the aforementioned 120-minute averaging period and 30-
minute averaging period. If an off-site source is suspected as the cause of an exceedance and the
trigger level continues to be exceeded despite full application of all relevant DCMs, it is
advisable to document the suspected cause and consult with the EPA PM to determine the best
course of action.16
Consistent with SCAQMD Rule 1466, Appendix A specifies that PMio monitors include a Data
Acquisition System capable of logging continuous direct-reading, near real-time data in 1-minute
averages. Some models allow users to send data to a cell phone and receive notifications if the
average PMio concentration exceeds a specified value. This enables the dust control
supervisor(s) to closely monitor PMio concentrations and to direct implementation of additional
dust suppression methods to avoid an exceedance of the trigger level over a 120-minute average
period.
16 Note that proper placement of the upwind PMio monitor(s) should capture PMio levels contributed by upwind off-
site sources, which are subtracted from PMio levels measured by the downwind monitor(s).
16
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5. OTHER DUST CONTROL PLAN COMPONENTS
Other important components of a DCP include appointing a dust control supervisor(s), posting
publicly visible site signage and contact information, recordkeeping, and compliance and
reporting. The substantive content of these DCP components should be described in TSCA
submittals.
5.1 Dust Control Supervisor
A dust control supervisor(s) is a person(s) assigned with the responsibility of observing and
overseeing dust control activities at the site. The dust control supervisor should always be
present when dust-generating activities occur at the site and given full authority to ensure that the
DCMs are being implemented and the specified air monitoring protocols and stipulations for
action levels are being followed. This authority should include inspections (e.g., checking for the
presence of visual dust plumes, checking stockpiles and disturbed surfaces for stabilization),
recordkeeping, and shutdown or modification of dust-generating activities.
The dust control supervisor may be an employee, contractor, or subcontractor of the site owner
or operator. The same individual responsible for overseeing PMio air monitoring at the site may
also serve as the dust control supervisor, provided they have the authority to direct on-site
personnel to cease earth-moving operations should the PMio trigger level be exceeded and to
increase the frequency and/or quantity of DCMs being implemented at the site as needed.
The name and contact information of the dust control supervisor does not need to be identified in
the TSCA submittal to EPA; following EPA's approval, the dust control supervisor's name
should be identified in the DCP prepared/utilized for the remedial action.
5.2 Site Signage
In order to inform the general public and provide a means for concerned residents or others to
report visible dust leaving the site, posting signs at the site's entrance and other visible locations
along the site perimeter is advised. Appendix A contains the following boilerplate text for
signage:
"THIS SITE CONTAINS SOILS [AND/OR OTHER MATERIAL] THAT CONTAIN[S]
POLY CHLORINATED BIPHYNLS (PCBs). TO REPORT ANY VISIBLE DUST LEAVING
THE SITE, PLEASE CALL [SITE CONTACT AND PHONE NUMBER] OR THE EPA
REGION [1-10] PROJECT MANAGER [NAME AND PHONE NUMBER OF SITE PROJECT
MANAGER]."
The italicized text should be customized to indicate which site media contain(s) PCBs and to add
contact information for the site owner/operator and the EPA Region PM for the site.
5.3 Recordkeeping
Appendix A contains example language that may be used for recordkeeping related to daily self-
inspections to document compliance with the DCP for each phase of remedial work.
Recordkeeping provisions in Appendix A extend to specifics concerning the dust suppression
17
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equipment utilized, the type of dust suppressant applied for each dust-generating activity, the
results of visual inspections, e.g., for dust plumes, track-out, and stockpiles, data results
associated with wind and PMio monitoring, performance checks, and maintenance, exceedances
of PMio trigger levels and response actions taken, and any complaints called in.
5.4 Compliance and Reporting
Appendix A contains example language that may be used for compliance and reporting,
including maintaining a complete copy of the DCP on site at all times during remedial activities,
providing copies of the DCP to all appropriate on-site workers, as well as making available the
DCP and daily recordkeeping documents for inspection by EPA during site visits.
The Appendix A example language also provides for the final DCP, along with records related to
daily self-inspections, to be submitted to EPA in the Cleanup Completion Report.
6. REFERENCES
California Air Resources Board "Inhalable Particulate Matter and Health (PM2.5 and PMIO)".
California Environmental Protection Agency (CalEPA), 2011. Guidance for Conducting
Emergency Debris. Waste and Hazardous Material Removal Actions Pursuant to a State or Local
Emergency Proclamation. October 2011.
Clark County Department of Air Quality (CCDAQ), 2000. Construction Activities Notebook
including the Section 94 Handbook. August 2000.
CCDAQ, 2020. Air Quality Regulations Section 94 - Permitting and Dust Control for
Construction Activities. January 2020.
CCDAQ, 2014. Air Quality Regulations Section 92 - Fugitive Dust from Unpaved Parking Lots
and Storage Areas. May 2014.
Environmental Protection Agency (EPA), 2022. List of Designated Reference and Equivalent
Methods. June 15, 2022.
EPA, 2011. Exposure I'netors Handbook: 2011 Edition.
EPA "NAAOS Table".
EPA Polychlorinated Biphenyls (PPv t 1 V ^ x l ;, Integrated Risk Information
System, Chemical Assessment Summary.
EPA, 2005. Polychlorinated Biphenyl (P< e Revitalization Guidance Under the Toxic
Substances Control Act (TSCA1 November 2005.
EPA. 2017. PCB Facilm U^roval Streamlining Toolb<»\ \ I u me work for Streamlining PCS
Site Cleanup Approvals. May 2017.
EPA, 2008. Quality Assurance Handbook for Air Pollution Measurement Svsten ime IV:
Meteorological Measurements. March 2008.
18
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South Coast Air Quality Management District (SCAQMD), 2005. Ru| itive Dust. June
2005.
SCAQMD, 2007. Rule 403 Implementation Handbook.. June 2007.
SCAQMD, 2021. Rule 1466. Control of Particulate Emissions from Soils with Toxic Air
Contaminants. June 4, 2021.
SCAQMD, 2021. Prclimin ¦ ¦ < naft Staff Report "moosed Amended Rut * s ^ »trol of
Particulate Emissions from Soils with Toxic Air Contaminants. February 2021.
19
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
1. General Project Information17
At a minimum, the Dust Control Plan (DCP) will include the following general project
information:
a) Project name, address and/or coordinates, and the applicable EPA project ID number;
b) Name, address, telephone number, and email address of owner or operator;
c) Name, telephone number, and email address of the Dust Control Supervisor(s);
d) Site description and any sensitive land uses18 near the site;
e) Information on the measured or expected concentrations of PCBs in site soils and/or
other materials;
f) A schedule of the estimated start and completion dates for each phase of remedial work;
g) A list of each applicable dust-generating activity;
h) A map of the specific remedial worksites with dust-generating activities that indicates the
area(s) containing PCB-impacted soil and/or other materials;
i) A map of the specific planned locations of PMio monitors, weather station or on-site
meteorology monitor, and windscreens; and
j) A copy of the local dust control rule or permit (if applicable).
The DCP will include the following specific Dust Control Measures (DCMs), Air Monitoring
trigger levels, procedures, and methods, and the following specific provisions for a Dust
Control Supervisor, Signage, Recordkeeping, and Compliance and Reporting.
2. Dust Control Measures
The following DCMs and Definitions will be included in the DCP. The DCMs will be
implemented at the site consistent with the Definitions provided.
Sitewide
1. Restrict Access: Access to the property and each remedial worksite will be restricted to
authorized vehicles and personnel.
2. Install Windscreens: Earth-Moving will not be conducted in a remedial worksite area
unless the worksite area is surrounded by fencing that is at a minimum 6 feet tall and at
17 Disclaimer: This document is intended to be used as an informal reference, and as such, is not a complete
statement of all applicable polychlorinated biphenyl (PCB) requirements. This document does not replace or
supplant the requirements of the Toxic Substances Control Act (TSCA) PCB regulations. Please refer to the PCB
regulations at 40 CFR part 761 for specific regulatory requirements. Also, these materials identify policies and
provide suggestions and do not create any new legal obligations or limit or expand obligations under any federal,
state, tribal, or local law.
18 For example, daycare centers, senior care centers, hospitals, schools, wetlands, endangered species habitats, etc.
1
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
least 6 inches taller than the tallest stockpile (if applicable), with a windscreen with a
porosity of 50 ± 5% or a mesh windscreen that has a shade value or opacity of 85 ± 5%.
3. Minimize Disturbed Area: Vehicle traffic and disturbance of soils peripheral to the area
of contaminated soil/materials removal will be limited to what is minimally necessary
with the use of fencing, barriers, barricades, and/or wind barriers.
4. Minimize Vehicle Speed: Signs will be posted at all entrances to the site to designate the
speed limit as 15 miles per hour (mph) in advance of the initiation of any Earth-Moving
Activity from a remedial work area(s) from which soil will be removed and transported
onsite or offsite.
5. Restrict Use of Mechanical Blowers: Mechanical blowers will not be used on any
surfaces within the Remedial Worksite or on any equipment or vehicles that have come
into contact with soil or other media originating from the Remedial Worksite.
6. Cease Operations During High Winds: Earth-Moving Activities will cease when there
are wind gusts that exceed 25 mph or if the wind speed is greater than 15 mph averaged
over a 15-minute period, except water trucks/pulls which will continue to operate unless
wind conditions are such that the continued operation of watering equipment cannot
reduce fugitive dust emissions or that continued equipment operation poses a safety
hazard. All stockpiles (of soil/media/materials) will be immediately covered with a
plastic sheeting at least 10 mil thick that overlaps a minimum of 24 inches and anchored
and secured so that no portion of the soil is exposed to the atmosphere.
7. Restrict Visible Dust Plumes:19 No person will cause or permit the handling (including
Earth-Moving), transportation, or storage of soil or other material in a manner that:
a. Allows a visible dust plume to extend more than one hundred (100) feet,
horizontally or vertically, from the point of origin; or
b. Allows a visible dust plume to cross the property boundary. If the TSCA Cleanup
Site extends to an adjacent property, this provision will be interpreted to apply to
the adjacent property's boundary when the PCB remedial activity is taking place
on the adjacent property.
8. Comply with Local Fugitive Dust Regulations: The requirements of all locally
applicable fugitive dust control rules will be followed.
19 These restrictions do not supersede other requirements to prevent the release of particulates or visible emissions.
Rather, they serve as readily observable visual indicators of a gross fugitive dust release that must be immediately
rectified to maintain compliance with the Dust Control Plan.
2
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
9. Project Phasing:20 Remedial activities will be conducted in phases to minimize the
amount of disturbed area at one time.
Excavating, Trenching, and Other Earth-Moving Activities
1. Pre-Water: Prior to disturbance, Dust Suppressant will be applied to Adequately Wet to
the depth of the Earth-Moving Activities allowing time for penetration.
2. Maintain Moisture: During Earth-Moving and handling of material, Dust Suppressant
will be applied to Adequately Wet at frequencies to prevent the generation of visible dust
plumes.
3. Stabilize or Cover: When Earth-Moving Activities are not occurring, Dust Suppressant
will be applied to maintain a Stabilized Surface in the Disturbed Surface Area, or the
Disturbed Surface Area will be covered with plastic sheeting at least 10 mil thick that
overlaps a minimum of 24 inches and is anchored and secured so that no portion of the
soil is exposed to the atmosphere.
Stockpiling
1. Stockpile Placement:21 Stockpiles will be placed on plastic sheeting in such a way that
spillage of materials that could contaminate other surfaces of the site will be avoided or
will only be placed on top of soil or other media that will be removed for disposal as part
of the PCB remediation plan.
2. Stockpile Maintenance: Stockpiles will be maintained to avoid steep sides and faces that
exceed the angle of repose.
3. Stockpile Size Restriction: Stockpiles will not exceed a volume of 400 cubic yards.
4. Stabilize or Cover:22 Dust Suppressant will be applied to the stockpile to maintain a
Stabilized Surface, or the stockpile will be covered with plastic sheeting at least 10 mil
thick that overlaps a minimum of 24 inches and is anchored and secured so that no
portion of the soil is exposed to the atmosphere.
5. Stockpile Daily Inspection: Stockpiles will be inspected at a minimum of once per day
to verify that the stockpiles are either stabilized or covered. Covered stockpile inspections
20 This DCM may only be relevant to larger sites with multiple remediation areas.
21 Applicable only to stockpiles containing PCB levels < 50 ppm, and consistent with the requirements of the PCB
Regulations including 40 CFR 761.1 (b)(5) ("No person may avoid any provision specifying a PCB concentration by
diluting the PCBs, unless otherwise specifically provided").
22 Id.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
will include a visual inspection of all seams and plastic cover surfaces to ensure that no
portion of the stockpile is exposed to the atmosphere.
6. Stockpiles with PCB Concentrations > 50 parts per million (ppm):23 Stockpiles with
PCB concentrations > 50 ppm will adhere to the following additional practices:
a. Placement: Stockpiles will be placed on plastic sheeting in such a way that
spillage of materials that could contaminate other surfaces of the site will be
avoided.
b. Covering - End of Day: At the end of each day, stockpiles will be covered with
a 10 mil thick plastic sheeting that overlaps at a minimum of 24 inches. The
sheeting will be anchored and secured so that no portion of the soil is exposed to
the atmosphere.
c. Temporary Storage: The stockpile will be tightly wrapped in sheet plastic for
temporary storage on-site prior to proper off-site disposal.
Truck Loading/Unloading and Transport
1. Designated Loading/Unloading Areas: Truck loading/unloading areas will be
established adjacent to or otherwise outside of the remedial excavation area(s) to avoid
haul truck travel on soils containing PCBs.
2. Pre-Water: Dust Suppressant will be applied to soil and/or other materials prior to
loading. Apply Dust Suppressant to soil and/or other materials prior to unloading.
3. Maintain Moisture: Dust Suppressant will be applied to Adequately Wet material
during loading and unloading activities at frequencies to prevent the generation of visible
dust plumes.
4. Drop Height: Drop height from the loader bucket will be minimized and the loader
bucket will be emptied slowly so that no visible dust plumes are generated.
5. Spilled Material: Prior to loading activities, plastic sheeting will be placed on the surface
beneath the trucks to collect any spilled material (e.g., soil). Any spilled material
collected on the plastic sheeting during loading activities will be removed such that truck
tires do not come into contact with it.
6. Freeboard Space: At least 6 inches of space between the soil and the top of the truck
bed and trailer (freeboard) will be maintained while transporting within a site.
23 See 40 CFR 761.65 for TSCA requirements applicable to storage for disposal of PCBs at concentrations > 50
ppm.
4
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
7. Load Covering: The truck bed and trailer will be completely covered prior to leaving the
site with a secured tarp to prevent material from blowing, dropping, leaking, or otherwise
escaping from the vehicle.
Track-out Prevention and Control
1. Use of Paved Surfaces for Trucks & Equipment:24 Operations of haul trucks will be
restricted to paved surfaces, as well as support equipment not directly involved in the
remedial excavation.
2. Track-out Control:25 The soil from the wheels and undercarriage of haul trucks and
trailers will be cleaned, without the use of forced air, prior to the vehicles leaving the site.
3. Track-out Control Devices:26 At least one of the following track-out control devices
will be installed and maintained in effective condition at all vehicle egress points where
paved and unpaved access or travel routes intersect. Traffic patterns will be established
and enforced to route traffic over the selected track-out control device(s).
a. Gravel Pad: Installation and utilization of a pad consisting of washed gravel
(minimum size 1 inch), maintained in a clean condition, to a depth of at least 6
inches extending at least 30 feet wide and at least 50 feet long. Re-screen, wash,
or apply additional rock in gravel pad to maintain effectiveness.
b. Wheel Shaker: Installation and utilization of a wheel shaker/wheel spreading
device consisting of raised dividers at least 24 feet long and 30 feet wide. Clean
wheel shaker on a regular basis to maintain effectiveness.
c. Wheel Washer: Installation and utilization of a wheel washer to remove soil
from tires and vehicle undercarriages. Maintain wheel washer on a regular basis
to maintain effectiveness (Note: water contaminated with PCBs will be
decontaminated (40 CFR § 761.79(b)(1)) or otherwise managed in accordance
with the PCB regulations at 40 CFR Part 761.)
d. Paved Surface: Enforcement of motorized vehicles to only operate on paved
surfaces.
24 This DCM is only relevant to sites with paved surfaces in close proximity to the remedial worksite and that extend
to the site exit.
25 The TSCA submittal should identify specific decontamination procedures for vehicles and equipment that have
come into contact with PCB remediation waste, consistent with 40 CFR 761.79.
26 Ibid. Note that a greywater tire wash to prevent trackout, if used as a final rinse to decontaminate vehicles before
exiting a PCB cleanup site, may not facilitate compliance with the PCB regulations. This is because, to the extent
the tire wash captures PCBs from vehicles egressing the site, reuse of the water could contaminate subsequent trucks
moving through the wash.
5
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
4. Deposition Limit: Deposition of track-out over 25 feet or more in cumulative length
onto a paved road will not be allowed and track-out will not be allowed to accumulate to
a depth greater than 0.25 inch on a paved road.
5. Deposition Removal: All accumulations of track-out on curbs, gutters, sidewalks, or
paved roads will be removed at a minimum frequency of once each day using a vacuum
equipped with a HEPA filter(s) rated by the manufacturer to achieve a 99.97% capture
efficiency for 0.3 micron particles. All track-out will be removed by the end of the
workday.
6. Track-out Daily Inspection: Track-out conditions on paved surfaces at each vehicle
egress point where paved and unpaved access or travel routes intersect will be inspected
at a minimum of once per day.
Disturbed Surface Areas
1. Access Prevention: Unauthorized access to the site will be prevented using fencing,
berms, ditches, vegetation, or another barrier.
2. Stabilize: Dust Suppressant will be applied to create and maintain a Stabilized Surface in
the Disturbed Surface Area.
Unpaved Roads, Haul Routes, and Parking Areas
1. Designated Haul Route(s): Unpaved haul routes will be established adjacent to or
otherwise outside of the remedial excavation area(s) to avoid haul truck travel on soils
containing PCBs.
2. Stabilize: Dust Suppressant, paving, or gravel will be applied to create and maintain a
Stabilized Surface on all unpaved roads, haul routes, and parking areas subject to
vehicular traffic.
3. Vehicle Speeds: Vehicle speeds will be limited to 15 miles per hour on all unpaved
roads, haul routes, and parking areas.
Pavement Removal
1. Pre-Water: Dust Suppressant will be applied immediately prior to crushing or cutting
into the paved material.
2. Maintain Moisture: Dust Suppressant will be applied to Adequately Wet material
during crushing or cutting activities at frequencies to prevent the generation of visible
dust plumes.
3. Stabilize:
6
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
a. Dust Suppressant will be applied to crushed material to form a Stabilized Surface
immediately following crushing.
b. Dust Suppressant will be applied to surfaces underlying removed concrete to
create a Stabilized Surface.
Paving/Subgrade Preparation
1. Pre-Water: Dust Suppressant will be applied to subgrade surface until Optimum Soil
Moisture content is reached and maintained.
2. Maintain Moisture: Dust Suppressant will be applied to Adequately Wet material
during activities until Optimum Soil Moisture content is reached and maintained.
3. Stabilize Adjacent Soils: Dust Suppressant will be applied following paving activities to
adjacent disturbed soils to create and maintain a Stabilized Surface.
Clearing or Cleaning Foundations and Slabs27
Foundations and slabs will be cleared or cleaned of soil or debris using water spray or
water spray in conjunction with hand tools (e.g., shovels, brooms) or an industrial
vacuum equipped with a High Efficiency Particulate Air (HEPA) filter(s) rated by the
manufacturer to achieve a 99.97% capture efficiency for 0.3 micron particles.
Storm Drain Sediment Cleanup28
1. Wetting: Sediment will be thoroughly wetted prior to removal, e.g., utilizing hydro-
jetting or a water hose with a high-pressure nozzle.
2. Dry Removal: Any dry sediment removal will be conducted using a High Efficiency
Particulate Air (HEPA)-equipped vacuum truck.
Investigation-Derived Waste (IDW)
1. Pre-Water: Prior to disturbance, Dust Suppressant will be applied to the soil in each
sampling location allowing time for penetration.
2. Maintain Moisture: During soil removal and handling, Dust Suppressant will be applied
to Adequately Wet at frequencies to prevent the generation of visible dust plumes.
27 Note that specific actions may be needed with respect to water and equipment (including vacuum components,
such as HEPA filters) used for PCB cleanup to meet TSCA PCB regulations for decontamination and/or disposal of
liquid PCB remediation waste and non-liquid PCB remediation waste (see 40 CFR §§ 761.79 and 761.61(a)(5)).
28 Ibid.
7
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
3. IDW Storage: IDW generated during investigations or well installations (e.g., drill
cuttings) will be placed in containers (e.g., 55-gallon drums) as soon as possible after
sampling. Containers will be covered with 10 mm thick plastic sheeting or the container
lids secured during times of inactivity to prevent the generation of windblown fugitive
dust. At the end of each workday, the plastic sheeting or container lids will be secured so
that no portion of the IDW is exposed. No IDW will be left on-site uncontained at the end
of a workday.
Other Dust-Generating Activities and Dust Control Measures
[Insert Other Dust-Generating Activities not included in the example language provided.]
[Insert other Dust Control Measures that may be feasible for the site cleanup.]
Dust Control Measures Definitions
Adequately Wet: The condition of being sufficiently mixed with water to prevent the
release of particulates or visible emissions. The process by which an adequately wet
condition is achieved is by using a dispenser or water hose with a nozzle that permits the
use of a fine, low-pressure spray or mist.
Adjacent Athletic Area: Any outdoor athletic field or park where youth organized sports
occur that is in physical contact with or is separated solely by a public roadway or other
public right-of-way to a school.
Adjoining: In physical contact with or separated solely by a public roadway or other
public right-of-way.
Clearing or Cleaning Foundations and Slabs: The clearing of PCB-contaminated soil,
sediment, and/or other debris that lies on top of a paved foundation or slab.
Cover: The installation of a temporary cover material on top of disturbed soil surfaces or
stockpiles, such as netting, mulch, wood chips, gravel, or other materials capable of
preventing wind erosion.
Crusting: The forming processes and the consequences of a thin layer at the soil surface
with reduced porosity and high penetration resistance. Crusting can be demonstrated
using the Soil Crust Test in Attachment 1.
Daycare Center: An establishment providing supervision of and care for preschool
children during the day.
Disturbed Surface Area: Portion of the earth's surface which has been physically
moved, uncovered, destabilized, or otherwise modified from its undisturbed natural soil
condition, thereby increasing the potential for fugitive dust. This definition excludes
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
those areas which have been restored to a natural state, such that the vegetative ground
cover and soil characteristics are similar to adjacent or nearby natural conditions; been
paved or otherwise covered by a permanent structure; or sustained a vegetative ground
cover of at least 70 percent of the native cover for a particular area for at least 30 days. It
also excludes any Unpaved Road, Haul Route, or Parking Area that has a Stabilized
Surface according to these Definitions.
Dust-Generating Activity: Process, method, operation, action, or land use that creates
emissions of fugitive dust or causes off-property or off-vehicle transport.
Dust Suppressant: Water, hydroscopic material, solution of water and chemical
surfactants, 29 non-toxic chemical stabilizer, or other dust palliative material which is not
prohibited for ground surface application by EPA or any applicable law or regulation, as
treatment material for reducing fugitive dust emissions.
Earth-Moving Activity: Any process that involves land clearing, disturbing soil
surfaces, excavating, trenching, backfilling, earth cutting and filling operations, moving,
uncovering, loading, unloading, adding to or removing from stockpiles, dredging,
grading, or handling of earth, dirt, soil, sand, sediment, aggregate, or similar materials,
and vehicular movement associated with these activities.
Enclosure: Either temporary or permanently installed structures or barriers that
completely surround a source(s) of fugitive dust emissions.
Fugitive Dust: Any solid particulate matter that is in contact with ambient air and has the
potential to become airborne, other than solid particulate matter that is emitted from an
exhaust stack.
Joint Use Agreement Property: A shared public facility in which a formal agreement
exists between a school and another government entity setting forth the terms and
conditions for shared use.
Optimum Soil Moisture Content: The water content at which soil can be compacted to
the maximum dry weight by modified compactive effort using ASTM D 1557 for
Optimum Soil Moisture Content/Maximum Density.
Owner or Operator: Any firm, business establishment, association, partnership,
corporation or individual, whether acting as principal, agent, employee, contractor, or in
any other capacity.
29 Where hydrophobic soils are present, use of a surfactant-water mixture may be needed for effective fugitive dust
control. Some site circumstances may warrant consideration of whether use of surfactant could increase the risk of
PCBs mobilizing into groundwater. However, because surfactant is generally only needed to facilitate permeation of
water in dry, hydrophobic soils to the depth of excavation, its application in the context of PCB cleanups may be
limited to sites located in arid areas that typically have deep water tables and PCB-impacted soils that will be
removed for disposal.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
Particulate Matter 10 (PMio): Particulate matter with an aerodynamic diameter smaller
than or equal to 10 microns as measured by the applicable State and Federal reference
test methods.
Paved Road: Public or private improved street, highway, alley, public way, or easement
that is covered by typical roadway materials, but excluding access roadways that connect
a facility with a public paved roadway and are not open to through traffic. Public paved
roads are those open to public access and that are owned by any federal, state, county,
municipal, or any other governmental or quasi-governmental agencies. Private paved
roads are any paved roads not defined as public.
Paving/Subgrade Preparation: The sub grade preparation for paving streets, parking
lots, or any other paved surface.
Property Boundary: The boundaries of a property subject to TSCA for which a
Responsible Party has the legal use or possession of the property. Where such property is
divided into one or more sub-tenancies, the property line(s) will refer to the boundaries
dividing the areas of all sub-tenancies.
Remedial Worksite: An area within a TSCA Cleanup Site where remedial activities are
planned, occurring, or have occurred to remove or clean up PCBs. There may be one or
more remedial worksites on a property.
School: Any public or private education center, including juvenile detention facilities
with classrooms, used for the education of more than 12 children at the education center
in kindergarten through grade 12. A school also includes an Early Learning and
Developmental Program by the U.S. Department of Education or any state or local early
learning or development programs such as preschools, Early Head Starts, Head Start,
First Five, and Child Development Centers. A school does not include any private
education center in which education is primarily conducted in private homes A school
includes any building or structure, playground, athletic field, or other area of school
property.
Senior Care Center: An establishment providing care for older adults including
residential care facilities, assisted living facilities, and nursing homes.
Stockpile: Any accumulation of bulk materials that contain particulate matter being
stored for future use or disposal. This includes backfill materials and storage piles for
soil, sand, dirt, mulch, aggregate, straw, chaff, or other materials capable of producing
dust.
Stabilized Surface: A stabilized surface is:
1. Any previously disturbed surface area or stockpile, which through the application
of a dust suppressant, shows visual or other evidence of surface crusting and is
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
resistant to wind driven fugitive dust, and is demonstrated to be stabilized.
Stabilization can be demonstrated using the Soil Crust Test in Attachment 1.
(Using a dust suppressant to maintain soil in a sufficiently damp condition such
that loose grains of soil are prevented from becoming dislodged when the Soil
Crust Test is conducted is acceptable evidence of a stabilized surface).
2. Any unpaved road, haul route, parking lot, or equipment storage area that shows
visual evidence of stabilization through the application of a dust suppressant,
pavement, or gravel, and is demonstrated to be stabilized. Stabilization can be
demonstrated using the Silt Content Test in Attachment 1.
TSCA Cleanup Site: The areal extent of contamination and all suitable areas in very
close proximity to the contamination necessary for implementation of a cleanup of PCB
remediation waste, regardless of whether the site was intended for management of
waste.
Track-Out: Any soil that adheres to and agglomerates on the exterior surface of motor
vehicles, haul trucks, and equipment (including tires) that has been released onto a paved
road and can be removed by a vacuum sweeper under normal operating conditions.
Unpaved Road, Haul Route, or Parking Area: Unpaved surfaces upon which vehicles
(including light-duty, medium-duty, and heavy-duty on-road or off-road equipment or
trucks) are operated or parked.
Wet Suppression: Use of water, including water combined with a chemical surfactant or
binding agent, to prevent the entrainment of dust into the air from fugitive dust sources.
Wheel Shaker: A device capable of spreading the tread on tires and shaking the wheels
and axles of vehicles for the purpose of releasing mud, soil, and rock from the tires and
undercarriage to prevent tracking those materials onto paved surfaces.
Wheel Washer: A station or device, either temporary or permanent, that utilized a bath
or spray of water for the purpose of cleaning mud, soil, and rock from the tires and
undercarriage of vehicles to prevent tracking those materials onto paved surfaces.
Wind Gust: The maximum instantaneous wind speed as measured by an anemometer.
30 40 CFR 761.3.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
[Use if applicable to site]
Sensitive Uses: Additional DCMs for TSCA Cleanup Sites Located at or Adjoining a
School, Joint Use Agreement Property, Adjacent Athletic Area, Daycare Center, or
Senior Care Center
1. Operation Hours: Earth-Moving Activities will only be conducted outside of the hours
between 7:30am and 4:30pm on days when the School/Day care Center/Senior Care
Center/Joint Use Agreement Property is in session.
2. Operation: Earth-Moving Activities will not be conducted if there is a School/Daycare
Center/Senior Care Center/Joint Use Agreement Property sponsored activity or youth
organized sports taking place at the site or on an Adjacent Athletic Area.
3. Excavated Soil Handling: Excavated soils containing PCBs will be handled by:
a. Immediately placing soil in a leak-tight container whereby any contained solids or
liquids are prevented from escaping or spilling out;
b. Directly loading soil in truck beds, trailers, or bins for transport, applying dust
suppressants, and completely covering prior to transporting; or
c. Stockpiling, pursuant to the Stockpiling DCMs, in a fenced area that is not
accessible to the general public and locked when not in use.
4. Excavated Soil Removal: Within five days of excavation, the excavated soil will be
removed from the site.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
3. Air Monitoring
Before Earth-Moving Activities or other Dust-Generating Activities begin on each workday
and throughout the duration of the Earth-Moving Activities or other Dust-Generating
Activities, continuous, direct-reading near-real time ambient monitoring of PMio
concentrations will be conducted. A minimum of two ambient PMio monitors will be used
that are identical in make and model, settings, and configuration. At least one PMio monitor
will be placed upwind and one PMio monitor downwind of the area(s) of on-site Earth-
Moving Activity or Dust-Generating Activity. The monitors will be placed as close to the
property line as feasible, or alternatively, at the remedial worksite perimeter.
Monitors will be operated, maintained, and calibrated in accordance with appropriate EPA-
published documents for PMio and manufacturer's instructions.
Equipment Specifications
Ambient PMio monitoring will be conducted in accordance with PMio monitors that meet the
following physical and performance requirements:31
1. PMio monitors will be continuous direct-reading near-real time monitors and will monitor
particulate matter less than 10 microns.
2. PMio monitors will be equipped with:
a. Omni-directional heated sampler inlet;
b. Sample pump with active flow control mechanism;
c. Enclosure;
d. Data logger capable of logging each data point with average concentration,
time/date, and data point number; and
e. Conductive tubing that minimizes particle loss for any external tubing used to
carry sampled air prior to measurement.
3. PMio monitors will meet the minimum performance standards:
a. Range: 0 - 1,000 |ig/m3;
b. Sensitivity 3 |ig/m3;
c. Accuracy, determined against an EPA Federal Reference Method or Federal
Equivalent Method:
i. ± 5% of reading precision; or
ii. Coefficient of determination (R2) of > 0.95 through simple linear
regression;
d. Resolution: 1.0 |ig/m3;
e. Flow control accuracy of ± 5% of factory setpoint; and
f. Measurement Cycle: User selectable (30 minute and 2 hour).
4. The PMio monitor user will include and document the appropriate QA/QC:
a. Instrument calibration;
31 Note that the South Coast AQMD has published a list of pre-approved PMio monitors for Rule 1466 that meet the
physical and performance requirements specified here: https://www.aqmd.gov/home/ailes~
compliance/compliance/aiie-1466/pre-approved-monitors.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
b. Instrument maintenance;
c. Operator training; and
d. Daily instrument performance checks.
e. Weekly instrument flow checks.
Monitoring Procedures and Methods
The PMio monitors will be operated with the heated sampler inlet on. The PMio data will be
collected with a Data Acquisition System (DAS) that is capable of logging direct-reading
near-real time data providing the date, time, and PMio concentration in micrograms per cubic
meter (|ig/m3) every 1 minute or less.
Prior to conducting any on-site Earth-Moving Activities or other Dust-Generating Activities,
and weekly thereafter, intra-instrument precision tests with the PMio monitors will be
conducted in accordance with Attachment 2 (Procedures to Demonstrate Intra-instrument
Precision).
Each day prior to conducting on-site Earth-Moving Activities or other Dust-Generating
Activities, a passing zero check on each PMio monitor will be conducted in accordance with:
Steps 4 and 5 of Attachment 2 demonstrating an average PMio concentration of 0 ± 3
|ig/m3; or
Manufacturer's instructions if a monitor is operated using an auto-zero check procedure
that directs filtered particle-free air into the measurement chamber.
Weather Station Monitor
When conducting ambient PMio monitoring, wind direction and speed will be monitored or
collected from a local National Weather Service (NWS) monitor (or equivalent
meteorological monitor) within five miles and subject to similar topography as specified in
U.S. EPA's Quality Assurance Handbook for Air Pollution Measurement Systems, Volume
IV: Meteorological Measurements32 using a minimum of one stationary anemometer or wind
sensor that:
1. Is sited over open, level terrain within the project site with minimal obstructions to wind
flow at a sufficient height to represent prevailing wind speed and direction;
2. Meets the performance criteria from Volume IV for SLAMS/SPM or NWS monitoring
of:
a. Wind direction accuracy of ± 5 degrees and resolution of 1 degree; and
b. Wind speed accuracy of ± or 5 percent above 5 mph of the observed windspeed,
whichever is greater, and resolution of 1 mph;
3. Has a National Institute of Standards and Technology (NIST) traceability certification;
4. Is equipped with a data logger that records wind direction and speed data once every 1
minute or less and archives the recorded wind direction and speed data, including the date
and time, calibrated to PST; and
32 https://www.epa.gov/sites/default/files/2021-04/documents/volume iv meteorological measiirements.pdf.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
5. Is operated, calibrated, and maintained in accordance with manufacturer's specifications,
but no less frequent than once every 6 months of cumulative operation.
Alternatively, an on-site meteorology monitor will be used to determine wind direction and
speed that meets the performance criteria specified in 1 through 5 above or at least one
properly sited windsock will be placed within the site. Approximate on-site wind direction
and speed from the windsock will be visually estimated and recorded every hour. Windsock
data will be compared to off-site meteorological data and used to aid in dust control
decisions.
Upwind and Downwind Air Monitor Placement
One or more air monitors will be located upwind of the area(s) of on-site Earth-Moving
Activity or other Dust-Generating Activity, indicative of background PMio levels, and not
generally influenced by fugitive dust sources from the site. The monitor(s) will be designated
as the "upwind monitor(s)". The placement of the upwind monitor(s) will be determined and
adjusted as needed based upon data recorded from an on-site meteorology monitor or an on-
site windsock.
One or more air monitors will be located downwind of the area(s) of on-site Earth-Moving
Activity or other Dust-Generating Activity. The monitor(s) will be designated as the
"downwind monitor(s)".
When there is a change in wind direction, as recorded from an on-site meteorology monitor
or windsock, the upwind monitor(s) will promptly be moved to the new upwind location and
the downwind monitor(s) will be moved to the new downwind location.
Calculation of PMio Concentration
The PMio concentration will be calculated by subtracting the results of the upwind monitor(s)
from the downwind monitor(s) for the same averaging period. When wind conditions are
stagnant or highly variable and no upwind and downwind impacts can be determined,
concentrations will be compared to the nearest regional background PMio monitor to estimate
impacts (if no local real-time background PMio data is available PM2.5 data can be considered
in this evaluation). If there is more than one upwind monitor, the upwind result is the average
concentration of all upwind monitors for the same rolling averaging period. If there is more
than one downwind monitor, the downwind result is the maximum of any of the downwind
monitors for the same rolling average period.
The PMio concentration will be calculated as a 120-minute rolling average where the initial
average starts at the commencement of on-site Earth-Moving Activities or other Dust-
Generating Activities and ends 120 minutes after the commencement of on-site Earth-
Moving Activities or other Dust-Generating Activities. The averages subsequent to the initial
average will be calculated every 1 minute and cover the previous 120-minute period.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
The calculated rolling average PMio concentrations for each 120-minute period and other
monitoring information collected shall be reported to EPA according to Sections VI and VII.
In the event that a DAS fails to log ambient PMio data or to calculate PMio concentrations
every 1 minute due to a technical issue beyond the reasonable control of the responsible
party, including, but not limited to, internet connection disruptions and computer
malfunctions, the following actions will be taken: (1) the DAS or data management system
will be restored to working condition as soon as practicable and no later than the start of the
next working day; and (2) PMio concentrations from the monitor(s) associated with the non-
operational DAS or data management system will be manually recorded every 10 minutes or
less and the PMio concentration calculated for every 120-minute rolling average until the
DAS or data management system is restored.
Air Monitoring Trigger Level
[The text below can be incorporated as applicable (depending upon the maximum PCB
concentration in soil).]
Earth-Movins Activities/Dust-Generatins Activities in an area(s) with a maximum PCB
concentration in soil of1.200 yym or less:
If the 120-minute average PMio concentration exceeds 25 micrograms per cubic meter
(|ig/m3), as measured and determined by protocols in Section III, all Earth-Moving Activities
and other Dust-Generating Activities shall cease and dust control measures, such as applying
dust suppressant to fugitive dust sources, shall be implemented as necessary until the PMio
concentration is equal to or less than 25 |ig/m3 averaged over 30 minutes.
Once the PMio concentration is equal to or less than 25 |ig/m3 averaged over 30 minutes, site
activities can resume. When activities resume after ceasing, the average shall start when on-
site Earth-Moving Activities or other Dust-Generating Activities resume and shall end 120
minutes after on-site Earth-Moving Activities or other Dust-Generating Activities resume,
and the subsequent averages are to be calculated every one minute and shall cover the
previous 120-minute period.
Earth-Movins Activities/Dust-Generatins Activities in an area(s) with a maximum PCB
concentration in soil of > 1.200 yym:
If the 120-minute average PMio concentration exceeds [Fill in site-specific trigger level
derived in accordance with Section 4 of EPA 's Fugitive Dust Control at TSCA PCB Cleanup
Sites] as measured and determined by protocols in Section III, all Earth-Moving Activities
and other Dust-Generating Activities shall cease and dust control measures, such as applying
dust suppressant to fugitive dust sources, shall be implemented as necessary until the PMio
concentration is equal to or less than [Fill in site-specific trigger level] averaged over 30
minutes.
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
Once the PMio concentration is equal to or less than [Fill in site-specific trigger level]
averaged over 30 minutes, site activities can resume. When activities resume after ceasing,
the average shall start when on-site Earth-Moving Activities or other Dust-Generating
Activities resume and shall end 120 minutes after on-site Earth-Moving Activities or other
Dust-Generating Activities resume, and the subsequent averages are to be calculated every
one minute and shall cover the previous 120-minute period.
4. Dust Control Supervisor
The site will have an on-site dust control supervisor(s) who is employed by or contracted
with the owner or operator. The dust control supervisor(s) will be designated in the DCP.
The DCP will include the dust control supervisor(s)' name, title, organization, telephone
number, and email address. [Add content addressing the dust control supervisor(s) '
qualifications.]
The following provisions listed in this section will be included in the DCP and implemented
at the site.
The dust control supervisor(s) will have full authority to ensure that the DCMs are
implemented and the specified air monitoring protocols and stipulations for action levels are
being followed. The authority will include inspections, recordkeeping, and shutdown or
modification of dust-generating activities. A designated dust control supervisor will be
present at all times when dust-generating activities occur on the site. The dust control
supervisor will meet any applicable fugitive dust training qualifications established by state
or local air pollution agencies.
The dust control supervisor will be responsible for confirming that all applicable DCMs are
being implemented, gauging the effectiveness of the DCMs applied throughout the workday,
e.g., checking for the presence of visual dust plumes and track-out, working with the
appropriate construction/demolition personnel to take corrective actions as needed, and
confirming that disturbed surfaces and stockpiles are stabilized or securely covered at the end
of the workday.
5. Signage
Prior to commencement of remedial work, proper signage will be posted and maintained on
site through each phase of remedial work until completion. The signage will be posted at all
entrances and at intervals of 1,000 feet along the perimeter of the site (except for any
entrance(s) or interval(s) along the property line or perimeter that is not visible and not
accessible to the public), with a minimum of one sign per side. The signs will be located
between 6 and 8 feet above grade from the bottom of the sign and display the following
information, including site-specific information, in lettering at least 4 inches tall with text
contrasting with the sign background:
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Appendix A - Dust Control Example Language
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
"THIS SITE CONTAINS SOILS [AND/OR OTHER MATERIAL] THAT
CONTAIN[S] POLYCHLORINATED BIPHYNLS (PCBs). TO REPORT ANY
VISIBLE DUST LEAVING THE SITE, PLEASE CALL [SITE CONTACT AND
PHONE NUMBER] OR THE EPA REGION [1-10] PROJECT MANAGER [NAME
AND PHONE NUMBER OF SITE PROJECT MANAGER]"
The DCP will include the plans for how signage will be posted at the site and include an
example of the posted signage language.
6. Recordkeeping
Records documenting compliance with the DCP will be completed for each phase of
remedial work (as applicable). Records will be retained for a minimum of one year following
the completion of the final phase of remedial work. The recordkeeping provisions listed in
this section will be included in the DCP and implemented at the site.
At minimum, the following information will be recorded as part of daily self-inspections (as
applicable):
a) Dust suppression equipment utilized (e.g., water truck, water hose) including equipment
type and size or holding capacity and hours of operation;
b) Type of dust suppressant applied for each dust-generating activity (e.g., water, water
combined with surfactant, chemical stabilizer);
c) Results of visual inspections for the presence of dust plumes and any corrective measures
taken to reduce or eliminate the dust plume(s);
d) Track-out inspection results of track-out conditions on paved surfaces and cleanup
measures taken (as applicable);
e) Inspections of all stabilized or covered stockpiles containing PCB-contaminated soils and
all re-stabilization, cover repair, and label maintenance activities including dates and
times the specific activities occurred;
f) Results of daily wind and PMio monitoring, including:
a. Rolling average ambient PMio concentrations for each 120-minute averaging
period; wind direction and speed corresponding to the rolling average PMio
concentrations; movement of monitoring instruments corresponding to wind
direction changes; instrument make and model; setting; proof of valid calibration
in accordance with the manufacturer's recommended schedule; configuration;
calibration, correction and correlation factors; maintenance; operator training; and
daily instrument performance check records and manual zero or auto-check
results; weekly zero calibration and flow check records and intra-instrument
precision test data and calculation results; and all instrument logs for monitoring
instruments;
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Appendix A - Dust Control Example Language
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control example language presented in this tool may not be applicable in all situations.
b. All instrument maintenance activities including: zero calibration, cleaning, filter
replacement, and performance checks, including dates and times of the specific
procedures; and
c. Documentation of all DAS and data management system failures, including date
and time of the failure, date and time of the correction, the technical issue(s)
causing the failure, and activities performed to restore the failed DAS or data
management system to working conditions;
g) Exceedances of PMio trigger levels and the response actions taken; and
h) Complaints called in, including the complaint, name of complainant, contact information,
date and time, activities occurring at that date and time, and actions taken.
7. Compliance and Reporting
The dust control supervisor will keep a complete copy of the DCP on-site at all times during
remedial activities for each phase of remedial work. Copies of the DCP, including DCMs and
related maps, will be supplied in advance of the initiation of remedial activities to all
contractors and subcontractors (including heavy equipment operators, water truck drivers,
haul truck drivers, and consultants handling air monitoring equipment). The DCP and daily
recordkeeping documents will be made available for inspection during on-site visits by the
EPA.
The RP or designated representative will submit the final DCP, along with documentation
listed in Section VI "Recordkeeping," to EPA in the Cleanup Completion Report.
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Appendix A - Dust Control Example Language Attachment 1
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
1. STABILIZED SURFACE TESTS
1.1 Soil Crust Test
Summary:
The purpose of this test is to check whether soil is sufficiently crusted to prevent generation of
windblown fugitive dust from Stockpiles and Disturbed Surface Areas.
At any given site, the existence of a sufficient crust on one portion of a large remedial work area
may not represent the existence or protectiveness of disturbed soil locations in other portions of
the remedial work area or in other remedial work areas at the site. Repeat the Soil Crust Test as
often as necessary in each remedial work area or portions thereof for an accurate assessment of
soil crusting of all disturbed surfaces.
Equipment:
Steel ball. Diameter: 5/8 (0.625) inches. Mass: 16-17 grams
Measuring tape or ruler
Optional: 1 ft by 1 ft carboard frame
Procedure:
1. Select a 1 ft by 1 ft survey area that is representative of the soil surface.
2. Clear blown sand away from the survey surface area.
3. Use a ruler to measure 1 ft above the surface, drop the steel ball from the 1 ft height into
the survey area.
4. Pass/Fail Determination: If you answer yes to any of the below questions, the surface has
failed the test. Note that if there is a slight indentation but no loose grains, the surface has
passed the test.
Did the ball sink into the surface so that it is partially or fully surrounded by loose
grains of material?
Has the ball sunk out of view?
After picking the ball up, are there loose grains of soil visible?
5. Select two additional areas within the 1 ft by 1 ft survey area and repeat Steps 2 and 3. If
the material passes at least two or all three tests, the survey area is considered to have
passed the test.
6. Select two additional 1 ft by 1 ft survey areas at random, making sure they are adequately
spaced and representative of the soil surface being tested. Repeat Steps 2, 3, and 4.
7. If all survey areas pass the test, the surface is stable and sufficiently crusted. If one or
more survey areas fail the surface is not stable. If the surface fails the test, but there are
minimal loose grains, the Threshold Friction Velocity (TFV) test method contained in
1
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Appendix A - Dust Control Example Language Attachment 1
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
SCAQMD Rule 403 Handbook33 may be conducted. If the surface passes the TFV test, it
is stable and sufficiently crusted.
1.2 Silt Content Test
The purpose of this test method is to estimate the silt content of the trafficked parts of Unpaved
Roads, Unpaved Haul Access Routes, Unpaved Parking Lots and Unpaved Equipment
Storage Areas. The higher the silt content, the greater the amount of fine dust particles entrained
into the atmosphere when cars and trucks drive on unpaved surfaces.
(a) Equipment needed:
(1) Set of sieves with openings of 4 mm, 2 mm, 1 mm, 0.5 mm, and 0.25 mm, along with
a lid and collector pan;
(2) Small whisk broom or paintbrush with stiff bristles and a dustpan one foot wide (the
broom/brush should preferably have one thin row of bristles no longer than 1.5 inches in
length);
(3) Spatula without holes;
(4) Small scale with half-ounce increments (e.g., postal/package scale);
(5) Shallow, lightweight container (e.g., plastic storage container);
(6) Sturdy cardboard box or other rigid object with a level surface;
(7) Basic calculator;
(8) Cloth gloves (optional for handling metal sieves on hot, sunny days);
(9) Sealable plastic bags (if sending samples to a laboratory); and
(10) Pencil/pen and paper.
(b) Look for a routinely traveled surface, as evidenced by tire tracks (only collect samples
from surfaces that are not damp from precipitation or dew). This statement is not meant
to be a standard in itself for dampness where watering is being used as a control measure;
it is only intended to ensure that surface testing is done in a representative manner. Use
caution when taking samples to ensure personal safety with respect to passing vehicles.
Gently press the edge of a dustpan (1 foot wide) into the surface four times to mark an
area that is 1 square foot. Collect a sample of loose surface material using a whisk broom
or paintbrush by slowly sweeping material into the dustpan, minimizing dust particle
escape. Use a spatula to lift heavier elements (such as gravel). Only collect dirt/gravel to
an approximate depth of 3/8 inch (1 cm) in the 1-square-foot area. If you reach a hard,
underlying subsurface more than 3/8 inch in depth, do not continue collecting the sample
by digging into the hard surface: in other words, only collect a surface sample of loose
material down to 1 cm. To confirm samples are collected to a depth of 1 cm, lay a
wooden dowel (or similar narrow object) at least 1 foot long horizontally across the
survey area while holding a metric ruler perpendicular to the dowel.
33 https://www.epa.gov/sYStem/files/dociHnents/2022-09/epa-approved-compiled-scaaiiKl-mles-regs-i-ii-iii-iv-v-
vii.pdf. See pdf pages 189-192.
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Appendix A - Dust Control Example Language Attachment 1
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
(1) At this point, the collected sample can be placed in a plastic bag or container and
taken to an independent laboratory for silt content analysis according to the test
procedure described in Volume 1, Appendix C.2.3 ("Silt Analysis") of Procedures for
Laboratory Analysis of Surface/Bulk Loading Samples (EPA 1995, 5th edition).
(c) Place the scale on a level surface. Place a lightweight container on the scale. Zero the
scale with the weight of the empty container on it. Transfer the entire sample collected in
the dustpan to the container, minimizing the escape of dust particles. Record the sample's
weight.
(d) Stack the set of sieves in order of size opening, placing the largest size (4 mm) at the top.
Place a collector pan underneath the bottom (0.25 mm) sieve.
(e) Carefully pour the sample into the sieve stack, minimizing escape of dust particles by
slowly brushing material into the stack with a whisk broom or brush (on windy days, use
the trunk or door of a car as a barricade). Cover the stack with a lid. Lift the sieve stack
and shake it vigorously up, down, and sideways for at least one minute.
(f) Remove the lid from the stack and disassemble each sieve separately, beginning at the
top. As each sieve is removed, examine it to make sure that all material has been sifted to
the finest sieve through which it can pass: i.e., the material in each sieve (besides the top
one, which captures a range of larger elements) should look the same size. If this is not
the case, restack the sieves and collector pan, cover the stack with the lid, and shake it
again for at least one minute. (Only reassemble the sieve(s) containing material that
requires further sifting).
(g) After disassembling the sieves and collector pan, slowly sweep the material from the
collector pan into the empty container originally used to collect and weigh the entire
sample. Take care to minimize escape of dust particles. Do not do anything with material
captured in the sieves, only that from the collector pan. Record the weight of the
container with the material from the collector pan.
(h) If the source is an Unpaved Road or Unpaved Haul Access Route, multiply the weight by
0.38; if the source is an Unpaved Parking Lot or Unpaved Equipment Storage Area,
multiply the weight by 0.55. The resulting number is the estimated silt loading. Divide by
the total weight of the sample recorded in step (b) and multiply by 100 to estimate the
percent silt content.
(i) Select another two routinely traveled portions of the Unpaved Road/Haul Access Route
or Unpaved Parking Lot/Equipment Storage Area and repeat this test method. Once you
have calculated the silt loading and percent silt content of the three samples collected,
average the results.
Examine the results. If the average silt loading is less than 0.33 oz/ ft2, the surface is stable. If the
average silt loading is greater than or equal to 0.33 oz/ft2, examine the average percent silt
3
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Appendix A - Dust Control Example Language Attachment 1
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
content. If the source is an Unpaved Road or Unpaved Haul Access Route and the average
percent silt content is 6% or less, the surface is stable. If the source is an Unpaved Parking Lot or
Unpaved Equipment Storage Area and the average percent silt content is 8% or less, the surface
is stable. If field test results are within 2% of the standard (i.e., 4-8% silt content on an Unpaved
Road or Unpaved Haul Access Route and 6-10% silt content on an Unpaved Parking Lot or
Unpaved Equipment Storage Area), collect three additional samples from the source (see step
(b)) and take them to an independent laboratory for silt content analysis.
4
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Appendix A - Dust Control Example Language Attachment 2
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
1. PROCEDURES TO DEMONSTRATE WEEKLY INTRA-INSTRUMENT
PRECISION AND FLOW VERIFICATION
The following procedures shall be performed to demonstrate the intra-instrument precision of all
PMio monitors.
Procedure:
1. Ensure monitors are identical in make and model, settings, and configuration.
2. Ensure monitor inlets are at the same height and located within 4 meters of each other but
no less than 1 meter apart for the duration of the test.
3. Power on the monitors and turn on the heated sampler inlet. Allow the monitors to warm
up per the manufacturer's recommendations or when readings have stabilized.
4. Verify total flow of each instrument is within 5% of manufacturer's specifications using
an NIST certified flow transfer standard. If flow is outside of specifications troubleshoot
and adjust accordingly.
5. For each monitor, conduct a zero calibration in accordance with the manufacturer's
instructions, then conduct a manual zero check by removing any sampling inlet and
installing a filter, rated by the manufacturer to achieve a 99.97 percent control efficiency
for 0.3-micron particles, on the inlet of the monitor for a minimum of 10 minutes. If the
monitors are operated using an auto-zero check procedure that directs filtered particle-
free air into the measurement chamber, conduct the zero check in accordance with
manufacturer's instructions.
6. Log the PMio concentrations reading every minute and calculate and record the average
of the readings of the manual zero check. The average manual zero check readings shall
be 0 ± 3 micrograms per cubic meter before proceeding to Step 7. If conducting an auto-
zero check, the monitor shall pass the zero check in accordance with the manufacturer's
instructions before proceeding to Step 7. If any monitors fail either the manual zero check
or the auto-zero check, the owner or operator shall conduct a zero calibration in
accordance with manufacturer's instructions and/or correct any issue(s) causing the
failure, followed by conducting a passing zero check on the PMio monitor(s) in
accordance with Step 5 and 6.
7. Remove the filter and install the monitor inlet as required. After waiting 10 minutes,
operate the monitors simultaneously and log the PMio concentration reading every
minute for a minimum of 60 minutes.
8. Calculate the intra-instrument precision using either of the following equations:
a. Intra-instrument precision in relative standard deviation or correlation of variation
(%) when ambient PMio concentrations are greater than or equal to 15
micrograms per cubic meter:
s
P = -^ x 100%
Where,
1
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Appendix A - Dust Control Example Language Attachment 2
This is an informational tool that does not create, limit, or expand legal obligations. The dust
control example language presented in this tool may not be applicable in all situations.
P = Intra-instrument precision (%)
Ct = Mean of the averaged PMio concentrations readings from all tested
monitors over the time t of testing duration
St = Standard deviation of the averaged PMio concentration readings from
all tested monitors over the time t of testing duration, to be calculated as:
x; = Mean of the PMio concentration readings for a tested monitor
over time t Of testing duration
x = Mean of averaged PMio concentration readings from all tested
monitors over the time t of testing duration
n = Number of tested monitors.
b. Intra-instrument precision in absolute value (micrograms per cubic meter) when
ambient PMio concentrations are less than 15 micrograms per cubic meter:
P = Insta-instrument micrograms per cubic meter
St = Standard deviation of the averaged PMio concentration readings from
all tested monitors over the time t of testing duration
9. Record the results of the calculations.
10. If the instruments fail precision or flow evaluations, corrective action must be taken to
address any potential impacts to previously collected data and to resolve discrepancies
prior to being put back into service.
Where,
P =st
Where,
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Appendix B - Dust-Generating Activity & Sensitive Use Example Checklist
This checklist can be used to identify site-specific dust-generating activities and sensitive uses
that may be applicable to a particular PCB Cleanup Site. See Appendix A for example language
(specifically, Dust Control Measures and associated Definitions) for each applicable Dust-
Generating Activity Category and Sensitive Use provided in this checklist. This example
checklist is not required to be used by a RP or submitted to EPA.
Site Name: Click or tap here to enter text.
EPA Site ID#: Click or tap here to
enter text.
Remedial Phase34: Click or tap here to enter text.
Review Date: Click or tap here to
enter text.
Dust-Generating Activity Category
Yes
No
Comments
1. Sitewide
X
This category applies to all PCB
cleanup sites with a dust-generating
activity(ies).
2. Excavating, Trenching, and/or
Other Earth-Moving Activity(ies)?
(any process that involves land
clearing, disturbing soil surfaces,
excavating, trenching, backfilling,
earth cutting andfilling operations,
moving, uncovering, loading,
unloading, adding to or removing
fi'om stockpiles, dredging, grading,
or handling of earth, dirt, soil, sand,
sediment, aggregate, or similar
materials, and vehicular movement
associated with these activities)
~
~
3. Stockpiling?
~
~
4. Truck Loading/Unloading and/or
Transport?
~
~
5. Track-Out Prevention and
Control?
(applies to sites where there is
potential for trucks, equipment, or
other vehicles to accumulate soil on
their tires and or exterior surfaces
prior to exiting the site)
~
~
6. Disturbed Surface Areas?
~
~
34 Use this box to indicate if there is more than one remedial phase applicable to the site (i.e., where PCB remedial
activities are proposed to be carried out in separate actions taking place on different dates). If so, fill out a checklist
for each remedial phase.
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Appendix B - Dust-Generating Activity & Sensitive Use Example Checklist
7. Unpaved Roads, Haul Routes,
and/or Parking Areas?
~
~
Dust-Generating Activity Category
Yes
No
Comments
8. Pavement Removal?
~
~
9. Paving/Subgrade Preparation?
~
~
10. Clearing or Cleaning Foundations
and/or Slabs?
~
~
11. Storm Drain Sediment Cleanup?
~
~
12. Investigation-Derived Waste? (e.g.,
more than one 5 5-gal drum)
~
~
13. Other Dust-Generating Activities
or Dust Control Measures?35
~
~
a. /Fill in]
~
~
b. [Fill in]
~
~
Sensitive Use Onsite or on an
Adjoining Site?36
Yes
No
Comments
1. School (including early education
center)?
~
~
2. Joint Use Agreement Property?
~
~
3. Athletic Area adjacent to a School
or Joint Use Agreement Property?
~
~
4. Daycare Center?
~
~
5. Senior Care Center?
~
~
6. Other sensitive human use?37
~
~
7. Sensitive ecological use?38
~
~
35 The "Other" category may be used to write in other sources of fugitive dust not included in the checklist, such as
demolition or renovation activities involving building materials containing PCBs.
36 See Appendix A "Dust Control Measures Definitions" for definitions applicable to Sensitive Uses.
37 Sensitive uses identified in this checklist are important but not exhaustive examples. For a particular cleanup site
it may be relevant to consider other proximate uses requiring dust control measures, such as uses that may be listed
in the PCB Regulations at 40 CFR 761.61(a)(4)(vi) [residential dwellings, hospitals, schools, nursing homes,
playgrounds, parks, day care centers, endangered species habitats, estuaries, wetlands, national parks, national
wildlife refuges, commercial fisheries, and sport fisheries] or 40 CFR 761.61(a)(l)(i) [surface or ground waters,
sediments in marine and freshwater ecosystems, sewers or sewage treatment systems, private or public drinking
water sources or distribution systems, grazing lands, or vegetable gardens].
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